SOC 2 - What is ACTUALLY required?

What are a few of the most common misconceptions about SOC 2 reports?

As someone who has managed the execution and delivery of countless such reports, I’m ready to lay a few of these to rest. I’ll start with my top 3: 

Examination Periods Have to be "X" Amount of Time

There's no precise AICPA requirement around the minimum period of time for SOC 2 Type 2 examinations. Theoretically, you could have a 1-month SOC 2 Type 2 report—it just may be difficult to find a reputable firm to do it.

That’s because it's up to the CPA firm to render an opinion that will provide "reasonable assurance" that the service organization’s commitments and system requirements were achieved based on the criteria. That’s likely not possible with a 1-month period, let alone 2-months. Our firm's stance is to allow 3-month periods for first-time reports and then at least 6-month periods in all subsequent reports. Regardless, we push for 12-month continuous periods so that there's no gap in the coverage of the assurance.

SOC 2 Reports are Required to Test All or Some of the Points of Focus

The points of focus are only a guideline. That doesn’t mean you should avoid them when designing controls to satisfy each criteria, but you theoretically could have a decent report even if you did. The only steadfast requirements are the trust services criteria. CPA firms work with service organizations to design controls so they can effectively opine on the design and operating effectiveness of each criteria. We typically design 3-6 controls per criteria, and some have upwards of 15 mapped controls.

This is, in part, because we try to design controls that will satisfy several different security questionnaires. This enables “a test once provide-to-all” approach to security compliance.

SOC 2 Results in a Certification

This can be confusing because SOC 2, for the most part, meets all the general definitions of a certification, provides a "logo" upon "passing" (like a certification) and maintains many of the attributes that other certifiable frameworks possess. The reason SOC 2 is not a certification is that it was created by the AICPA and is governed by its standards and codes of conduct. Therefore, SOC 2 is truly a reporting framework that produces an attestation report based on an examination of controls.

Of course, this is by no means an exhaustive list of the common misconceptions surrounding SOC 2 reports. If you know of any others, I invite you to reach out and continue the conversation.

Related Resources

• Schneider Downs SOC Report Brochure
• Schneider Downs SOC FAQs

About Schneider Downs IT Risk Advisory

Schneider Downs’ team of experienced risk advisory professionals focuses on collaborating with your organization to identify and effectively mitigate risks. Our goal is to understand not only the risks related to potential loss to the organization but to drive solutions that add value to your organization and advise on opportunities to ensure minimal disruption to your business.

To learn more, visit our dedicated IT Risk Advisory page.